THOMAS P. VALENTI, PC v. Swanson

In this case we are asked to rule that an attorney may not recover legal fees under a theory of quantum meruit if he fails to comply with the Personal Injury Representation Agreement Act (Act) (815 ILCS 640/0.01 et seq. (West 1996)). We disagree that such a holding is required by Illinois law and thus affirm the trial court’s judgement.

FACTS

The facts are relatively undisputed. On October 7, 1994, Lorraine and Arthur Swanson were involved in an automobile accident. Four days later, they hired attorney Valenti to represent them on a contingent fee basis. Valenti did not provide the Swansons…